- 6 - from 1999 to taxes petitioner owed for 1994 and applied only petitioner’s three estimated tax payments for 2000 totaling $7,938.87 to petitioner’s 2000 tax liability, respondent determined that petitioner underpaid his taxes for 2000 by $3,152.35 ($11,091.22 - $7,938.87). Respondent also assessed a penalty for underpayment of estimated tax and interest. The transcript of petitioner’s 2000 taxes shows that on November 5 and 12, 2001, respondent sent petitioner notices of balance due for his 2000 taxes. On July 30, 2002, petitioner filed a petition for bankruptcy under 11 U.S.C chapter 7 seeking discharge of his tax liabilities for 1992-95. On November 13, 2002, the bankruptcy court granted petitioner a discharge of those taxes. On October 14, 2003, respondent issued a Final Notice of Intent to Levy and Notice of Right to a Hearing with respect to petitioner’s 2000 tax liability. Petitioner filed a timely request for a hearing. On March 24, 2004, Appeals Officer Jacquelyn Sansbury met with petitioner. Appeals Officer Sansbury had no prior involvement with regard to petitioner’s tax liabilities. At the meeting, petitioner asserted the proposed collection of the 2000 taxes was improper because the Internal Revenue Service (IRS) ignored his direction to apply the 1999 overpayment to his 2000 estimated taxes.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011